OFAC FAQ (Current) # 661 - Executive Order 13850 "Blocking Property of Additional Persons Contributing to the Situation in Venezuela"

Date issued: May. 12 2020

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TURBOFAC Commentary (609 words)


Note: this FAQ and comments thereto were posted/written prior to the blocking of the Government of Venezuela pursuant to EO 13884. Neither the FAQ nor the comment have been updated in light of that development. However, the FAQ was updated on May 13, 2020, to reflect the unblocking of Nynas AB and concurrent removal of that entity from the scope of GL 9.

1) The proviso that "any divestment or transfer of, or facilitation of divestment or transfer of, any holdings in such PdVSA securities must be to a non-U.S. person" leaves vague whether intra-company or intra-fund transfers are permitted without a license. Technically, those actions are a "transfer" of holdings, but OFAC's reference to "secondary market" restrictions suggests it may consider some intra-company transfers of interests to U.S. persons as within the scope of the GL. In any case, such transfers...